DHARMENBHAI MAHENDRABHAI SUTARIA,HUF,AHMEDABAD vs. ACIT, CENTRAL CIRCLE-1(2), , AHMEDABAD

In the result appeal of the assessee is hereby allowed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalasstt. Sr.No.

u/s 271(1)(c) of the Act would be set aside. 9.5.7 In the case of CIT v. SAS Pharmaceuticals 11 taxmann.com 207 (Delhi), the Delhi High Court held that for imposing penalty under section 271(1)(c), concealment of particulars of income or furnishing of inaccurate particular of income by assessee has to be in income-tax return filed

DEPUTY COMMISSIONER OF INCOME -TAX, CENTRAL CIRCLE-1(1), AHMEDABAD, AHMEDABAD vs. PRIYA BLUE INDUSTRIES PVT. LTD., GUJARAT

In the result the appeals filed by the Revenue in ITA No

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

271 or section 271BA if any person in respect of an international transaction or specified domestic transaction, - (i) fails to keep and maintain any such information and document as required by sub-section (1) or sub-section (2) of section 920, (ii) fails to report such transaction which he is required to do so, or (iii) maintains or furnishes

DCIT CENTRAL CIRCLE 1(1), AHMEDABAD, GUJARAT vs. PRIYA BLUE INDUSTRIES PVT. LTD., GUJARAT

In the result the appeals filed by the Revenue in ITA No

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

271 or section 271BA if any person in respect of an international transaction or specified domestic transaction, - (i) fails to keep and maintain any such information and document as required by sub-section (1) or sub-section (2) of section 920, (ii) fails to report such transaction which he is required to do so, or (iii) maintains or furnishes

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1), GUJARAT vs. PRIYA BLUE INDUSTRIES PVT. LTD., GUJARAT

In the result the appeals filed by the Revenue in ITA No

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

271 or section 271BA if any person in respect of an international transaction or specified domestic transaction, - (i) fails to keep and maintain any such information and document as required by sub-section (1) or sub-section (2) of section 920, (ii) fails to report such transaction which he is required to do so, or (iii) maintains or furnishes

DEPUTY COMMISSIONER OF INCOME -TAX, CENTRAL CIRCLE 1(1), AHMEDABAD, AHMEDABAD vs. PRIYA BLUE INDUSTRIES PVT. LTD, GUJARAT

In the result the appeals filed by the Revenue in ITA No

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

271 or section 271BA if any person in respect of an international transaction or specified domestic transaction, - (i) fails to keep and maintain any such information and document as required by sub-section (1) or sub-section (2) of section 920, (ii) fails to report such transaction which he is required to do so, or (iii) maintains or furnishes

DEPUTY COMMISSIONER OF INCOME -TAX, CENTRAL CIRCLE-1(1), AHMEDABAD, GUJARAT vs. PRIYA BLUE INDUSTRIES PVT. LTD., GUJARAT

In the result the appeals filed by the Revenue in ITA No

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

271 or section 271BA if any person in respect of an international transaction or specified domestic transaction, - (i) fails to keep and maintain any such information and document as required by sub-section (1) or sub-section (2) of section 920, (ii) fails to report such transaction which he is required to do so, or (iii) maintains or furnishes

RAVINDRABHAI SHANKARBHAI PATEL,VADODARA vs. THE ITO, WARD-1(2)(5) NOW ITO, WARD-1(2)(2), VADODARA

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalthe Ito Ravindrabhai Shankarbhai Vs. Ward-1(2)(5). Patel Now Ito, Ward-1(2)(2) 86,Kanha Residency Vadodara – 390 007 Kalali Road, Kalali Ahmedabad – 390 012 [Pan : Aigpp 8415 M] (Appellant) (Respondent) .. Assessee Represented By : Ms. Urvashi Shodhan, Ar Revenue Represented By : Shri Abhijit, Sr.Dr Date Of Hearing 27/11/2025 Date Of Pronouncement 29/01/2026

271(1)(c) of the Act were also initiated. Ravindrabhai Shankarbhai Patel vs. ITO A.Y: 2015-16 5. Aggrieved by the assessment order, the assessee carried the matter in appeal before the Commissioner of Income Tax (Appeals). Before the CIT(Appeals), the assessee contended that all the conditions of sections 54B and 54F were duly complied with. It was submitted

SADBHAV ENGINEERING LTD.,AHMEDABAD vs. DCIT, CENTRAL CIRCLE 1(3), AHMEDABAD, DCIT, CENTRAL CIRCLE 1(3), AHMEDABAD

In the result, all the appeals of the assessee are partly allowed\nand that of the Revenue are dismissed

section 153A of the Act is to be treated as return\nfiled under section 139(1) of the Act. The Ld.Counsel for the assessee\nhas borrowed this proposition to contend that accordingly fresh\nclaims can be made in returns filed u/s 153A of the Act. But, we find,\nthat these decisions have been rendered while addressing completely\ndifferent issue, relating

AVANI DIPAKBHAI SHAH,VADODARA vs. THE ACIT, CIRCLE INTL. TXN., VADODARA

The appeal of the assessee is allowed

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

4– of Shri Harsh D. Shah under section 69 of the Act, it was not conclusively established who was the real beneficiary of the loan transaction. Accordingly, to safeguard the interest of the Revenue, the Assessing Officer completed the assessment under section 153C read with section 144 on 19.05.2022, adding ₹7,32,68,860/- to the total income

AVANI DIPAKBHAI SHAH,VADODARA vs. THE ACIT, CIRCLE INTL. TXN., VADODARA

The appeal of the assessee is allowed

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

4– of Shri Harsh D. Shah under section 69 of the Act, it was not conclusively established who was the real beneficiary of the loan transaction. Accordingly, to safeguard the interest of the Revenue, the Assessing Officer completed the assessment under section 153C read with section 144 on 19.05.2022, adding ₹7,32,68,860/- to the total income

AVANI DIPAKBHAI SHAH,VADODARA vs. THE ACIT, CIRCLE INTL. TXN., VADODARA

The appeal of the assessee is allowed

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

4– of Shri Harsh D. Shah under section 69 of the Act, it was not conclusively established who was the real beneficiary of the loan transaction. Accordingly, to safeguard the interest of the Revenue, the Assessing Officer completed the assessment under section 153C read with section 144 on 19.05.2022, adding ₹7,32,68,860/- to the total income

AXIS BANK LIMITED,AHMEDABAD vs. THE ACIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, the appeal of the assessee is partly allowed

Bench: Ms. Suchitra Raghunath Kamble & Shri Narendra Prasad Sinha

4 Ahmedabad Bench of Tribunal in the order dealing with merits on the underlying issue. 1.7. The learned AO and Hon'ble CIT(A) erred in relying on the decision in case of Dharamendra Textiles Processors [306 ITR 277) (2008) (SC) without appreciating the fact that the same is not applicable to the instant case as the Appellant

AXIS BANK LIMITED,AHMEDABAD vs. THE ACIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, the appeal of the assessee is partly allowed

Bench: Ms. Suchitra Raghunath Kamble & Shri Narendra Prasad Sinha

4 Ahmedabad Bench of Tribunal in the order dealing with merits on the underlying issue. 1.7. The learned AO and Hon'ble CIT(A) erred in relying on the decision in case of Dharamendra Textiles Processors [306 ITR 277) (2008) (SC) without appreciating the fact that the same is not applicable to the instant case as the Appellant

AXIS BANK LIMITED,AHMEDABAD vs. THE ACIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, the appeal of the assessee is partly allowed

Bench: Ms. Suchitra Raghunath Kamble & Shri Narendra Prasad Sinha

4 Ahmedabad Bench of Tribunal in the order dealing with merits on the underlying issue. 1.7. The learned AO and Hon'ble CIT(A) erred in relying on the decision in case of Dharamendra Textiles Processors [306 ITR 277) (2008) (SC) without appreciating the fact that the same is not applicable to the instant case as the Appellant

AXIS BANK LIMITED,AHMEDABAD vs. THE ACIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, the appeal of the assessee is partly allowed

Bench: Ms. Suchitra Raghunath Kamble & Shri Narendra Prasad Sinha

4 Ahmedabad Bench of Tribunal in the order dealing with merits on the underlying issue. 1.7. The learned AO and Hon'ble CIT(A) erred in relying on the decision in case of Dharamendra Textiles Processors [306 ITR 277) (2008) (SC) without appreciating the fact that the same is not applicable to the instant case as the Appellant

AXIS BANK LIMITED,AHMEDABAD vs. THE ACIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, the appeal of the assessee is partly allowed

Bench: Ms. Suchitra Raghunath Kamble & Shri Narendra Prasad Sinha

4 Ahmedabad Bench of Tribunal in the order dealing with merits on the underlying issue. 1.7. The learned AO and Hon'ble CIT(A) erred in relying on the decision in case of Dharamendra Textiles Processors [306 ITR 277) (2008) (SC) without appreciating the fact that the same is not applicable to the instant case as the Appellant

MAHAVEER SINGH,AHMEDABAD vs. THE PCIT, AHMEDABAD-1, AHMEDABAD

In the result, the appeal filed by the Assessee is hereby dismissed

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

271(1)(c) of the Act. Therefore we are of the considered opinion, the revisionary jurisdiction invoked u/s. 263 by directing the Assessing Officer to issue correct penalty notice by modifying the reassessment order is well within the provisions of law, which does not require any interference. 10. Respectfully following the above decision of Co-ordinate Bench of this Tribunal

GUJARAT MEDICAL EDUCATION AND RESEARCH SOCIETY AHMEDABAD,GANDHINAGAR vs. THE DY.CIT, CIRCLE-1, EXEMP, AHMEDABAD

In the result, the appeals of the assessee for A

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

u/s. 271(l)(c) of the Act for Rs.166,50,03,312 be deleted. ITA Nos. 2612 to 2616/Ahd/2025 Gujarat Medical Education and Research Society Ahmedabad vs. DCIT Asst. Years –2015-16 & 2018-19 - 4– 4. Without prejudice to the above, the learned CIT(A) has also erred in upholding the penalty under section 271